Prior art teaches numerous approaches for restraining a person's upper body, in particular, to restraining an infant's head during transport in strollers, car seats, infant carriers, swings, cribs, bassinets, bouncer seats, high chairs, etc. For example, head restraining supports are disclosed in U.S. Pat. Nos. 5,383,711 to Houghteling; 5,339,472 to Yin; 5,310,245 to Lyszczasz; 5,272,780 to Clute; 5,248,182 to Hittie; 5,228,745 to Hazel; 5,220,700 to Liu; 5,211,696 and 5,154,477 to Lacy; 5,161,855 to Harmon; 5,161,522 to Clevenger; 5,127,120 and 4,402,548 to Mason; 4,838,611 to Talaugon; 4,779,930 to Rosen; 4,738,488 to Camelio; and 4,383,713 to Roston.
The Houghteling patent, in particular, discloses an infant head support attached to a liner sheet or to a rectangular base member. This liner sheet or base member, which is placed on an infant carrier or seat, is padded and dimensioned at least partially to underlie the infant's upper body. A pair of laterally spaced rectangular head support members, which form the head support, are attached directly to the liner sheet or rectangular base member. These rectangular head support members, made of resilient cushion having no internal frame, are rolled or folded so that they support opposite lateral portions of the infant's head. The Lyszczasz, Harmon, and Clute patents describe similar structures.
The Mason ('548) and Clevenger patents describe another type of head supports, where the head supporting members are adjustably or slidably attached directly to the back of a seat. The Lucy patents describe similar head supports, a single-cushion pillow type attached to a head rest or a seat back. Another example of a single cushion pillow type, which directly rests on the infant's or child's neck, is described in the Yin, Talaugon, and Camelio patents. Further, a conformal body or head pad type is disclosed in the Roston, Rosen, Mason ('120), and Hazel patents.